The Prosecutor of the International Criminal Tribunal for the former Yugoslavia,
pursuant to her authority under Article 18 of the Statute of the International
Criminal Tribunal for the former Yugoslavia ("the Statute of the Tribunal"),
charges:

SLOBODAN MILOSEVIC

with GENOCIDE, CRIMES AGAINST HUMANITY, GRAVE BREACHES OF THE GENEVA CONVENTIONS
and VIOLATIONS OF THE LAWS OR CUSTOMS OF WAR as set forth below:

THE ACCUSED

1. Slobodan MILOSEVIC,son of Svetozar Milosevic,was
born on 20 August 1941 in Pozarevac, in the present-day Republic of Serbia,
one of the constituent republics of the Federal Republic of Yugoslavia ("FRY").
In 1964, he graduated from the Law Faculty of the University of Belgrade and
began a career in management and banking. Until 1978, he held the posts of deputy
director and later general director at Tehnogas, a major oil company
in the then Socialist Federal Republic of Yugoslavia ("SFRY"). Thereafter,
he became president of Beogradska banka (Beobanka), one of the largest
banks in the SFRY, a post he held until 1983.

2. Slobodan MILOSEVIC,joined the League of Communists of Yugoslavia
in 1959. In 1984, he became Chairman of the City Committee of the League of
Communists of Belgrade. In 1986, he was elected Chairman of the Presidium of
the Central Committee of the League of Communists of Serbia and was re-elected
in 1988. On 16 July 1990, the League of Communists of Serbia and the Socialist
Alliance of Working People of Serbia united, forming a new party named the Socialist
Party of Serbia ("SPS"). On 17 July 1990, Slobodan MILOSEVIC
was elected President of the SPS and remained in that post except during the
period from 24 May 1991 to 24 October 1992.

3. Slobodan MILOSEVIC was elected President of the Presidency of the
then Socialist Republic of Serbia on 8 May 1989 and re-elected on 5 December
1989. After the adoption of a new Constitution, on 28 September 1990, the Socialist
Republic of Serbia became the Republic of Serbia, and Slobodan MILOSEVIC
was elected to the newly established office of President of the Republic of
Serbia in multi-party elections, held in December 1990. He was re-elected to
this office in elections held on 20 December 1992.

4. After serving two terms as President of the Republic of Serbia, Slobodan
MILOSEVIC was elected President of the Federal Republic of Yugoslavia on
15 July 1997, beginning his official duties on 23 July 1997. Following his defeat
in the Federal Republic of Yugoslaviaís presidential election of September 2000,
Slobodan MILOSEVIC relinquished his position on 6 October 2000.

INDIVIDUAL CRIMINAL RESPONSIBILITY

Article 7(1) of the Statute of the Tribunal

5. Slobodan MILOSEVIC is individually criminally responsible for the
crimes referred to in Articles 2, 3, 4 and 5 of the Statute of the Tribunal
as described in this indictment, which he planned, instigated, ordered, committed,
or in whose planning, preparation, or execution he otherwise aided and abetted.
By using the word "committed" in this indictment, the Prosecutor does
not intend to suggest that the accused physically committed any of the crimes
charged personally. "Committed" in this indictment refers to participation
in a joint criminal enterprise as a co-perpetrator.

6. Slobodan MILOSEVIC participated in the joint criminal enterprise
as set out below. The purpose of this joint criminal enterprise was the forcible
and permanent removal of the majority of non-Serbs, principally Bosnian Muslims
and Bosnian Croats, from large areas of the Republic of Bosnia and Herzegovina
(hereinafter referred to as "Bosnia and Herzegovina"), through the
commission of crimes which are in violation of Articles 2, 3, 4 and 5 of the
Statute of the Tribunal.

7. The joint criminal enterprise was in existence by 1 August 1991 and continued
until at least 31 December 1995. The individuals participating in this joint
criminal enterprise included Slobodan MILOSEVIC, Radovan KARADZIC, Momcilo
KRAJISNIK, Biljana PLAVSIC, General Ratko MLADIC, Borisav JOVIC, Branko KOSTIC,
Veljko KADIJEVIC, Blagoje ADZIC, Milan MARTIC, Jovica STANISIC, Franko SIMATOVIC,
also known as "Frenki," Radovan STOJICIC, also known as "Badza,"
Vojislav SESELJ, Zeljko RAZNATOVIC, also known as "Arkan," and other
known and unknown participants.

8. The crimes enumerated in Counts 1 to 29 of this indictment were within
the object of the joint criminal enterprise. Alternatively, the crimes enumerated
in Counts 1 to 15 and 19 to 29 were natural and foreseeable consequences of
the execution of the object of the joint criminal enterprise and the accused
was aware that such crimes were the possible outcome of the execution of the
joint criminal enterprise.

9. In order for the joint criminal enterprise to succeed in its objective,
Slobodan MILOSEVIC worked in concert with or through other individuals in
the joint criminal enterprise. Each participant or co-perpetrator within the
joint criminal enterprise, sharing the intent to contribute to the enterprise,
played his or her own role or roles that significantly contributed to achieving
the objective of the enterprise. The roles of the participants or co-perpetrators
include, but are not limited to, the following:

10. Radovan KARADZIC was President of the Serbian Democratic Party of Bosnia
and Herzegovina (Srpska demokratska stranka Bosne i Hercegovine or "SDS")
throughout the period of the indictment. On 27 March 1992, KARADZIC became the
President of the Bosnian Serb "National Security Council." On 12 May
1992, he was elected President of the three-member Presidency of the self-proclaimed
Serbian Republic of Bosnia and Herzegovina (hereinafter referred to as "Republika
Srpska") and remained in this position after the Presidency was expanded
to five members on 2 June 1992. On 17 December 1992, KARADZIC was elected President
of Republika Srpska and remained in that position throughout the period of this
indictment. In his capacity as a member of the Bosnian Serb National Security
Council, member of the Presidency, as President of Republika Srpska, and in
his position of leadership within the SDS party and organs of the Republika
Srpska government, Radovan KARADZIC, together with others, commanded, directed,
or otherwise exercised effective control over the Territorial Defence ("TO"),
the Bosnian Serb army ("VRS") and the police forces of Republika Srpska
who participated in the crimes specified in this indictment.

11. Momcilo KRAJISNIK, a close associate of Radovan KARADZIC, was a member
of the SDS Main Board from 12 July 1991. On 24 October 1991, the day of the
founding of the "Assembly of the Serbian People of Bosnia and Herzegovina,"
(hereinafter referred to as the "Bosnian Serb Assembly") KRAJISNIK
was elected its President. From 27 March 1992, KRAJISNIK was a member of the
Bosnian Serb National Security Council. He became a member of the five-member
Presidency on 2 June 1992. When the Bosnian Serb Assembly elected Radovan KARADZIC
President of Republika Srpska on 17 December 1992, KRAJISNIK ceased to be a
member of the Presidency, but continued to be one of the most important political
leaders in Republika Srpska and remained the President of its National Assembly
until 19 October 1996. In his capacity as a member of the Bosnian Serb National
Security Council as a member of the Presidency of Republika Srpska, and in his
position of leadership within the SDS party and organs of the Republika Srpska
government, Momcilo KRAJISNIK, together with others, commanded, directed, or
otherwise exercised effective control over the TO, the VRS and the police forces
of Republika Srpska who participated in the crimes specified in this indictment.

12. Biljana PLAVSIC, a high-ranking SDS politician, on 28 February 1992, became
one of two Acting Presidents of the Serbian Republic of Bosnia and Herzegovina,
together with Nikola KOLJEVIC. As an Acting President, Biljana PLAVSIC became
an ex officio member of the Bosnian Serb National Security Council. On
12 May 1992, she was elected as a member of the three-member Presidency and
remained in this position after it was expanded to five members. When the Bosnian
Serb Assembly elected Radovan KARADZIC President of Republika Srpska on 17 December
1992, it also elected Biljana PLAVSIC one of two Vice-Presidents, a position
she held until 19 July 1996. In her capacity as Vice-President, member of the
Bosnian Serb National Security Council as a member of the Presidency of Republika
Srpska, and in her position of leadership within the SDS party and organs of
the Republika Srpska government, Biljana PLAVSIC, together with others, commanded,
directed, or otherwise exercised effective control over the TO, the VRS and
the police forces of Republika Srpska who participated in the crimes specified
in this indictment.

13. General Ratko MLADIC, a military career officer previously stationed in
Macedonia and Kosovo, became the commander of the 9th Corps (Knin
Corps) of the Yugoslav Peopleís Army ("JNA") in June 1991 and participated
in the fighting in Croatia. On 4 October 1991, the SFRY Presidency promoted
him to Major General. Subsequently, in May 1992, he assumed command of the forces
of the Second Military District of the JNA in Sarajevo. From 12 May 1992 until
November 1996, he was the Commander of the Main Staff of the VRS and in this
capacity, together with others, commanded, directed, or otherwise exercised
effective control over the VRS and other units acting in co-ordination with
the VRS who participated in the crimes specified in this indictment.

14. Borisav JOVIC was successively the Vice-President, President and then a
member of the SFRY Presidency from 15 May 1989 until April 1992, as well as
the President of the SPS from May 1991 until October 1992, and a high ranking
official of the SPS until November 1995. Borisav JOVIC and Branko KOSTIC, the
Vice-President and then Acting President of the Presidency of the SFRY, together
with others during the relevant period, commanded, directed, or otherwise exercised
effective control over the JNA and members of the TO and paramilitary units
acting in co-ordination with, and under supervision of, the JNA.

15. General Veljko KADIJEVIC,asFederal Secretary for National
Defence from 15 May 1988 until 6 January 1992, commanded, directed, or otherwise
exercised effective control over the JNA and other units acting in co-ordination
with the JNA.

16. General Blagoje ADZIC, in his capacity as JNA Chief of Staff from 1990
to 28 February 1992 and Acting Federal Secretary for National Defence from mid-1991
to 28 February 1992, Federal Secretary for National Defence from 28 February
1992 to 27 April 1992 and JNA Chief of Staff from 27 April 1992 to 8 May 1992,
together with others, commanded, directed, or otherwise exercised effective
control over the JNA and other units acting in co-ordination with the JNA.

17. Jovica STANISIC, in his capacity as chief of the State Security (Drzavna
bezbednost or "DB") of the Republic of Serbia from March 1991
to October 1998, commanded, directed, or otherwise exercised effective control
over members of the DB, who participated in the perpetration of the crimes specified
in this indictment. In addition, he provided arms, funds, training, or other
substantial assistance or support to Serb paramilitary units and police units
that were subsequently involved in the crimes specified in this indictment.

18. Franko SIMATOVIC, also known as "Frenki," as head of the special
operations component of the DB of the Republic of Serbia, commanded, directed,
or otherwise exercised effective control over agents of the DB who perpetrated
crimes specified in this indictment. In addition, he provided arms, funds, training,
or other substantial assistance or support to Serb paramilitary units and police
units that were subsequently involved in the crimes charged in this indictment.

19. Radovan STOJICIC also known as "Badza" as Deputy Minister of
Interior of Serbia and head of Public Security Service, commanded, directed
or otherwise exercised effective control over special forces of the Serbian
MUP and volunteer units who participated in the crimes specified in this indictment.
In addition, he provided arms, funds, training, or other substantial assistance
or support to Serb paramilitary units and police units that were subsequently
involved in the crimes specified in this indictment.

20. Milan MARTIC, as "Secretary of the Secretariat of Internal Affairs"
of the so-called Serbian Autonomous Region ("SAO") Krajina from 4
January 1991 until 29 May 1991; as "Minister of Defence" of the SAO
Krajina from 29 May 1991 to 27 June 1991; and as "Minister of Internal
Affairs" for the SAO Krajina (later "Republic of Serbian Krajina")
from 27 June 1991 to January 1994, established, commanded, directed, and otherwise
exercised effective control over members of his police force (referred to as
"Marticís Police," "Marticís Militia," "Marticevci,"
"SAO Krajina Police" or "SAO Krajina Militia") who were
subsequently involved in the crimes specified in this indictment.

21. Zeljko RAZNATOVIC, also known as "Arkan," in 1990 established
and commanded the Serbian Volunteer Guard, a paramilitary unit commonly known
as "Arkanovci" or "Arkanís Tigers," who during the time
relevant to this indictment operated in Bosnia and Herzegovina and were involved
in the crimes charged in this indictment. In addition, he maintained a significant
military base in Erdut, Croatia, where he functioned as commander. Other paramilitary
groups and TO units were trained at this base and were subsequently involved
in the crimes charged in this indictment.

22. Vojislav SESELJ, as President of the Serbian Radical Party (SRS) from
at least February 1991 throughout the time relevant to this indictment recruited
or otherwise provided substantial assistance or support to Serb paramilitary
units, commonly known as "Seseljevci" or "Seseljís men,"
who perpetrated crimes as specified in this indictment. In addition, he openly
espoused and encouraged the creation of a "Greater Serbia" by violence
and other unlawful means, and actively participated in war propaganda and spreading
inter-ethnic hatred.

23. From 1987 until late 2000, Slobodan MILOSEVIC was the dominant
political figure in Serbia and the SFRY/FRY. He acquired control of all facets
of the Serbian government, including the police and the state security services.
In addition, he gained control over the political leaderships of Kosovo, Vojvodina,
and Montenegro.

24. In his capacity as the President of Serbia and through his leading position
in the SPS party, Slobodan MILOSEVIC exercised effective control or substantial
influence over the above listed participants in the joint criminal enterprise
and either alone or acting in concert with them and additional known and unknown
persons effectively controlled or substantially influenced the actions of the
Federal Presidency of the SFRY and later the FRY, the Serbian Ministry of Internal
Affairs ("MUP"), the JNA, the Yugoslav Army ("VJ") and the
VRS, as well as Serb paramilitary groups.

25. Slobodan MILOSEVIC, acting alone and in concert with other members
of the joint criminal enterprise participated in the joint criminal enterprise
in the following ways:

a) He exerted effective control over elements of the JNA and VJ which participated
in the planning, preparation, facilitation and execution of the forcible
removal of the majority of non-Serbs, principally Bosnian Muslims and Bosnian
Croats, from large areas of Bosnia and Herzegovina.

b) He provided financial, logistical and political support to the VRS.
These forces subsequently participated in the execution of the joint criminal
enterprise through the commission of crimes which are in violation of Articles
2, 3, 4 and 5 of the Statute of the Tribunal.

c) He exercised substantial influence over, and assisted, the political
leadership of Republika Srpska in the planning, preparation, facilitation
and execution of the take-over of municipalities in Bosnia and Herzegovina
and the subsequent forcible removal of the majority of non-Serbs, principally
Bosnian Muslims and Bosnian Croats, from those municipalities.

d) He participated in the planning and preparation of the take-over of
municipalities in Bosnia and Herzegovina and the subsequent forcible removal
of the majority of non-Serbs, principally Bosnian Muslims and Bosnian Croats,
from those municipalities. He provided the financial, material and logistical
support necessary for such take-over.

e) He participated in the formation, financing, supply, support and direction
of special forces of the Republic of Serbia Ministry of Internal Affairs.
These special forces participated in the execution of the joint criminal
enterprise through the commission of crimes which are in violation of Articles
2, 3, 4 and 5 of the Statute of the Tribunal.

f) He participated in providing financial, logistical and political support
and direction to Serbian irregular forces or paramilitaries. These forces
participated in the execution of the joint criminal enterprise through the
commission of crimes which are in violation of Articles 2, 3, 4 and 5 of
the Statute of the Tribunal.

g) He controlled, manipulated or otherwise utilised Serbian state-run media
to spread exaggerated and false messages of ethnically based attacks by
Bosnian Muslims and Croats against Serb people intended to create an atmosphere
of fear and hatred among Serbs living in Serbia, Croatia and Bosnia and
Herzegovina which contributed to the forcible removal of the majority of
non-Serbs, principally Bosnian Muslims and Bosnian Croats, from large areas
of Bosnia and Herzegovina.

26. Slobodan MILOSEVIC knowingly and wilfully participated in the joint
criminal enterprise, while being aware of the foreseeable consequences of this
enterprise. On this basis, he bears individual criminal responsibility for these
crimes under Article 7(1) of the Statute of the Tribunal, in addition to his responsibility
under the same Article for having planned, instigated, ordered or otherwise aided
and abetted in the planning, preparation and execution of these crimes.

Article 7(3) of the Statute of the Tribunal

27. Slobodan MILOSEVIC, while holding positions of superior authority,
is also individually criminally responsible for the acts or omissions of his
subordinates, pursuant to Article 7(3) of the Statute of the Tribunal. A superior
is responsible for the criminal acts of his subordinates if he knew or had reason
to know that his subordinates were about to commit such acts or had done so,
and the superior failed to take the necessary and reasonable measures to prevent
such acts or to punish the perpetrators.

28. From at least March 1991 until 15 June 1992, Slobodan MILOSEVIC
exercised effective control over the four members of the "Serbian Bloc"
within the Presidency of the SFRY. These four individuals were Borisav JOVIC,
the representative of the Republic of Serbia; Branko KOSTIC, the representative
of the Republic of Montenegro; Jugoslav KOSTIC, the representative of the Autonomous
Province of Vojvodina; and Sejdo BAJRAMOVIC, the representative of the Autonomous
Province of Kosovo and Metohija. Slobodan MILOSEVIC used Borisav JOVIC
and Branko KOSTIC as his primary agents in the Presidency and through them he
directed the actions of the "Serbian Bloc." From 1 October 1991, in
the absence of the representatives of the Presidency from Croatia, Slovenia,
Macedonia and Bosnia and Herzegovina, the four members of the "Serbian
Bloc" exercised the powers of the Presidency, including that of collective
"Commander-in-Chief" of the JNA. This "Rump Presidency"
acted without dissension to execute Slobodan MILOSEVICís policies. The
Federal Presidency had effective control over the JNA as its "Commander-in-Chief"
and other units under the supervision of the JNA. Generals Veljko KADIJEVIC
and Blagoje ADZIC, who directed and supervised the JNA forces in Bosnia and
Herzegovina, were in constant communication and consultation with the accused.

29. On 27 April 1992, the Supreme Defence Council was formed. Throughout the
time relevant to this indictment, Slobodan MILOSEVIC was a member of
the Supreme Defence Council and exercised substantial influence and control
over other members of the Council. The Supreme Defence Council and the President
of the FRY had de jure control over the JNA and later the VJ. In addition
to his de jure powers, at all times relevant to this indictment, Slobodan
MILOSEVIC exercised de facto controlover theJNA and
the VJ through his control over the high ranking officers of these armies.

30. Slobodan MILOSEVIC is therefore individually criminally responsible,
under Article 7(3) of the Statute of the Tribunal, for the participation of
the members of the JNA and the VJ and other units under the supervision of the
JNA and the VJ in the crimes described in this indictment.

31. From the time Slobodan MILOSEVIC came to power in Serbia, he exercised
control over key officials in the Serbian MUP, among them Radmilo BOGDANOVIC
and Zoran SOKOLOVIC, who were both, at different times, the Minister of Internal
Affairs of Serbia. He also exercised control over Jovica STANISIC and Franko
SIMATOVIC, both high-ranking officials in the DB. Through these officials, Slobodan
MILOSEVIC exercised effective control over agents of the MUP, including
the DB, who directed and supported the actions of the special forces and Serb
paramilitary groups operating in Bosnia and Herzegovina. The accused Slobodan
MILOSEVIC is therefore individually criminally responsible, under Article
7(3) of the Statute of the Tribunal, for the participation of the members of
the Serbian MUP, including the DB, in the crimes described in this indictment.

THE CHARGES

COUNTS 1 and 2
GENOCIDE OR COMPLICITY IN GENOCIDE

32. From on or about 1 March 1992 until 31 December 1995, Slobodan MILOSEVIC,
acting alone or in concert with other members of the joint criminal enterprise,
planned, instigated, ordered, committed or otherwise aided and abetted the planning,
preparation and execution of the destruction, in whole or in part, of the Bosnian
Muslim and Bosnian Croat national, ethnical, racial or religious groups, as
such, in territories within Bosnia and Herzegovina, including: Bijeljina; Bosanski
Novi; Bosanski Samac; Bratunac; Brcko; Doboj; Foca; Sarajevo (Ilijas); Kljuc;
Kotor Varos; Sarajevo (Novi Grad); Prijedor; Rogatica; Sanski Most; Srebrenica;
Visegrad; Vlasenica and Zvornik. The destruction of these groups was effected
by:

a) The widespread killing of thousands of Bosnian Muslims and Bosnian Croats,
during and after the take-over of territories within Bosnia and Herzegovina,
including those listed above, as specified in Schedule A to this indictment.
In many of the territories, educated and leading members of these groups were
specifically targeted for execution, often in accordance with pre-prepared
lists. After the fall of Srebrenica in July 1995, almost all captured Bosnian
Muslim men and boys, altogether several thousands, were executed at the places
where they had been captured or at sites to which they had been transported
for execution.

b) The killing of thousands of Bosnian Muslims and Bosnian Croats in detention
facilities within Bosnia and Herzegovina, including those situated within
the territories listed above, as specified in Schedule B to this indictment.

c) The causing of serious bodily and mental harm to thousands of Bosnian
Muslims and Bosnian Croats during their confinement in detention facilities
within Bosnia and Herzegovina, including those situated within the territories
listed above, as specified in Schedule C to this indictment. Members
of these groups, during their confinement in detention facilities and during
their interrogation at these locations, police stations and military barracks,
were continuously subjected to, or forced to witness, inhumane acts, including
murder, sexual violence, torture and beatings.

d) The detention of thousands of Bosnian Muslims and Bosnian Croats in detention
facilities within Bosnia and Herzegovina, including those situated within
the territories listed above, under conditions of life calculated to bring
about the partial physical destruction of those groups, namely through starvation,
contaminated water, forced labour, inadequate medical care and constant physical
and psychological assault.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 1: GENOCIDE, punishable under Articles 4(3)(a) and
7(1) and 7(3) of the Statute of the Tribunal; or

Count 2: COMPLICITY IN GENOCIDE, punishable under Articles
4(3)(e) and 7(1) and 7(3) of the Statute of the Tribunal.

34. Throughout this period, Serb forces, comprised of JNA, VJ, VRS units, local
TO units, local and Serbian MUP police units and paramilitary units from Serbia
and Montenegro, attacked and took control of towns and villages in these territories.
After the take-over, the Serb forces in co-operation with the local Serb authorities
established a regime of persecutions designed to drive the non-Serb civilian
population from these territories.

35. These persecutions were committed on the discriminatory grounds of political
affiliation, race or religion and included:

a) The extermination or murder of thousands of Bosnian Muslim, Bosnian Croat
and other non-Serb civilians, including women and the elderly, in those territories
listed above, the details of which are set out in Schedules A and B
to this indictment.

b) The prolonged and routine imprisonment and confinement of thousands of
Bosnian Muslim, Bosnian Croat and other non-Serb civilians in detention facilities
within and outside of Bosnia and Herzegovina, the details of which are set
out in Schedule C to this indictment.

c) The establishment and perpetuation of inhumane living conditions against
Bosnian Muslim, Bosnian Croat and other non-Serb civilians, within the above
mentioned detention facilities. These living conditions were brutal and characterised
by inhumane treatment, overcrowding, starvation, forced labour and systematic
physical and psychological abuse, including torture, beatings and sexual assault.

d) The prolonged and frequent forced labour of Bosnian Muslim, Bosnian Croat
and other non-Serb civilians, from these detention facilities. The forced
labour included digging graves and trenches and other forms of manual labour
at the frontlines.

e) The cruel and inhumane treatment of Bosnian Muslim, Bosnian Croat and
other non-Serb civilians during and after the take-over of the municipalities
specified above. Such inhumane treatment included, but was not limited to,
sexual violence, torture, physical and psychological abuse and forced existence
under inhumane living conditions.

f) The imposition of restrictive and discriminatory measures against Bosnian
Muslims, Bosnian Croats and other non-Serbs, such as, the restriction of freedom
of movement; removal from positions of authority in local government institutions
and the police; dismissal from jobs; arbitrary searches of their homes; denial
of the right to judicial process and the denial of the right of equal access
to public services, including proper medical care.

g) The beating and robbing of Bosnian Muslim, Bosnian Croat and other non-Serb
civilians.

h) The forcible transfer and deportation of thousands of Bosnian Muslim,
Bosnian Croat and other non-Serb civilians, from the territories listed above,
to locations outside of Serb held territories as described in paragraphs 40
and 41 and Schedule D to this indictment.

i) The appropriation and plunder of property belonging to Bosnian Muslim,
Bosnian Croat and other non-Serb civilians.

j) The intentional and wanton destruction of homes, other public and private
property belonging to Bosnian Muslims and Bosnian Croats, their cultural and
religious institutions, historical monuments and other sacred sites, as described
in paragraph 42.

k) The obstruction of humanitarian aid, in particular medical and food supplies
into the besieged enclaves Bihac, Gorazde, Srebrenica and Zepa, and the deprivation
of water from the civilians trapped in the enclaves designed to create unbearable
living conditions.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 3: Persecutions on political, racial or religious grounds,
a CRIME AGAINST HUMANITY, punishable under Articles 5(h) and 7(1) and
7(3) of the Statute of the Tribunal.

a) The killing of Bosnian Muslims, Bosnian Croats and other non-Serbs in
their towns and villages, during and after the take-over of the territories
listed above including those specified in Schedule A to this indictment.

b) The killing of Bosnian Muslims, Bosnian Croats and other non-Serbs in
detention facilities and during their deportation or forcible transfers, including
those specified in Schedule B to this indictment.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 4: Extermination, a CRIME AGAINST HUMANITY, punishable
under Articles 5(b) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 5: Murder, a CRIME AGAINST HUMANITY, punishable under
Articles 5(a) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 6: Wilful killing, a GRAVE BREACH OF THE GENEVA CONVENTIONS
OF 1949, punishable under Articles 2(a) and 7(1) and 7(3) of the Statute
of the Tribunal.

Count 7: Murder, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR,
as recognised by Common Article 3(1)(a) of the Geneva Conventions of 1949, punishable
under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

38. Serb military forces, comprised of JNA, VJ, VRS, TO and paramilitary units
acting in co-operation with local police staff and local Serb authorities, arrested
and detained thousands of Bosnian Muslim, Bosnian Croat and other non-Serb civilians
from the territories listed above. These civilians were held in short and long-term
detention, of which the major facilities are specified in Schedule C
to this indictment.

39. The living conditions in these detention facilities were brutal and characterised
by inhumane treatment, overcrowding, starvation, forced labour, inadequate medical
care and systematic physical and psychological assault, including torture, beatings
and sexual assault.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 8: Imprisonment, a CRIME AGAINST HUMANITY, punishable
under Articles 5(e) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 9: Torture, a CRIME AGAINST HUMANITY, punishable
under Articles 5(f) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 10: Inhumane acts, a CRIME AGAINST HUMANITY, punishable
under Articles 5(i) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 11: Unlawful Confinement, a GRAVE BREACH OF THE GENEVA
CONVENTIONS OF 1949, punishable under Articles 2(g) and 7(1) and 7(3)
of the Statute of the Tribunal.

Count 12: Torture, a GRAVE BREACH OF THE GENEVA CONVENTIONS
OF 1949, punishable under Articles 2(b) and 7(1) and 7(3) of the Statute
of the Tribunal.

Count 13: Wilfully causing great suffering, a GRAVE BREACH
OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(c) and
7(1) and 7(3) of the Statute of the Tribunal.

Count 14: Torture, a VIOLATIONS OF THE LAWS OR CUSTOMS OF WAR
as recognised by Common Article 3(1)(a) of the Geneva Conventions of 1949,
punishable under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

Count 15: Cruel Treatment, a VIOLATIONS OF THE LAWS OR CUSTOMS
OF WAR as recognised by Common Article 3(1)(a) of the Geneva Conventions
of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the
Tribunal.

41. In order to achieve this objective, Serb forces comprised of JNA, VJ,
VRS and TO, paramilitary units acting in co-operation with local police staff,
local Serb authorities and special forces of the Serbian Ministry of Internal
Affairs under the effective control of Slobodan MILOSEVIC or other members
of the joint criminal enterprise, subjugated villages and towns in Bosnia and
Herzegovina and participated with members of the SDS in the disarming of the
non-Serb population. The towns and villages, including areas in which the inhabitants
complied and offered no resistance, were then attacked. These attacks were intended
to compel the non-Serb population to flee. After taking control of the towns
and villages, the Serb forces often rounded-up the remaining non-Serb civilian
population and forcibly removed them from the area. On other occasions, the
Serb forces in co-operation with the local Serb authorities imposed restrictive
and discriminatory measures on the non-Serb population and engaged in a campaign
of terror designed to drive them out of the territory. The majority of non-Serbs
that remained were eventually deported or forcibly transferred from their homes.

By these acts and omissions Slobodan MILOSEVIC committed:

Count 16: Deportation, a CRIME AGAINST HUMANITY, punishable
under Articles 5(d) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 17: Inhumane Acts (Forcible Transfers), a CRIME AGAINST
HUMANITY, punishable under Articles 5(i) and 7(1) and 7(3) of the Statute
of the Tribunal.

Count 18: Unlawful Deportation or Transfer, a GRAVE BREACH
OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(g) and
7(1) and 7(3) of the Statute of the Tribunal.

COUNTS 19 to 22WANTON DESTRUCTION, PLUNDER OF PUBLIC OR PRIVATE PROPERTY

a) The appropriation and plunder of property belonging to Bosnian Muslim,
Bosnian Croat and other non-Serb civilians, including the coerced signing
of documents relinquishing property rights.

b) The intentional and wanton destruction of homes and other property owned
by Bosnian Muslim, Bosnian Croat and other non-Serb civilians. Such destruction
was employed as a means to compel non-Serbs to flee their legal domiciles
and to prevent their subsequent return.

c) The intentional and wanton destruction of religious and cultural buildings
of the Bosnian Muslim and Bosnian Croat communities including, but not limited
to, mosques, churches, libraries, educational buildings and cultural centres.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 19: Extensive destruction and appropriation of property, not
justified by military necessity and carried out unlawfully and wantonly, a GRAVE
BREACH OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(d)
and 7(1) and 7(3) of the Statute of the Tribunal.

Count 20: Wanton destruction of villages, or devastation not justified
by military necessity, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, punishable
under Articles 3(b) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 21: Wilful destruction or wilful damage done to historic monuments
and institutions dedicated to education or religion, a VIOLATION OF THE LAWS
OR CUSTOMS OF WAR, punishable under Articles 3(d) and 7(1) and 7(3) of the
Statute of the Tribunal.

Count 22: Plunder of public or private property, a VIOLATION OF
THE LAWS OR CUSTOMS OF WAR, punishable under Articles 3(e) and 7(1) and
7(3) of the Statute of the Tribunal.

43. Between April 1992 and November 1995, Slobodan MILOSEVIC, acting
alone or in concert with members of the joint criminal enterprise, planned,
instigated, ordered, committed, or otherwise aided and abetted the planning,
preparation, or execution of a military campaign of artillery and mortar shelling
and sniping onto civilian areas of Sarajevo and upon its civilian population,
killing and wounding thousands of civilians of all ages and both sexes.

44. In this time period, the Sarajevo Romanija Corps of the VRS, under the
effective control of Radovan KARADZIC and General Ratko MLADIC, launched an
extensive, forty-four month shelling and sniping attack on Sarajevo, mostly
from positions in the hills surrounding the city with an unobstructed view of
Sarajevo.

45. The Sarajevo Romanija Corps conducted a protracted campaign of shelling
and sniping upon Sarajevo during which civilians were either specifically targeted
or the subject of reckless fire into areas where civilians were known to have
been. Among the victims of this campaign were civilians who were, amongst other
things, tending vegetable plots, queuing for bread or water, attending funerals,
shopping in markets, riding on trams, gathering wood. Specific instances of
sniping are described in Schedule E attached to this indictment. Specific
instances of shelling are set forth in Schedule F.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 23:Murder, a CRIME AGAINST HUMANITY, punishable
under Articles 5(a) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 24:Inhumane acts, a CRIME AGAINST HUMANITY,
punishable under Articles 5(i) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 25:Wilful killing, a GRAVE BREACH OF THE GENEVA
CONVENTIONS OF 1949, punishable under Articles 2(a) and 7(1) and 7(3)
of the Statute of the Tribunal.

Count 26:Wilfully causing great suffering, a GRAVE BREACH
OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(c) and
7(1) and 7(3) of the Statute of the Tribunal.

Count 27:Murder, a VIOLATION OF THE LAWS OR CUSTOMS
OF WAR, as recognised by Common Article 3(1)(a) of the Geneva Conventions
of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the
Tribunal.

Count 28:Cruel treatment, a VIOLATION OF THE LAWS OR
CUSTOMS OF WAR, as recognised by Common Article 3(1)(a) of the Geneva
Conventions of 1949, punishable under Articles 3 and 7(1) and 7(3) of the
Statute of the Tribunal.

Count 29:Attacks on civilians, a VIOLATION OF THE LAWS
OR CUSTOMS OF WAR, as recognised by Article 51 (2) of Additional Protocol
I and Article 13 (2) of Additional Protocol II to the Geneva Conventions of
1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the
Tribunal.

GENERAL LEGAL ALLEGATIONS

46. All acts and omissions alleged in this indictment occurred on the territory
of the former Yugoslavia.

47. At all times relevant to this indictment, a state of international armed
conflict and partial occupation existed in Bosnia and Herzegovina.

48. All acts and omissions charged as Grave Breaches of the Geneva Conventions
of 1949 occurred during the international armed conflict and partial occupation
of Bosnia and Herzegovina. All such acts and omissions were committed against
persons protected under the Geneva Conventions.

49. All acts and omissions charged relative to the destruction of property
as Grave Breaches of the Geneva Conventions of 1949 involved "protected
property" under the relevant provisions of the Geneva Conventions.

50. At all times relevant to this indictment Slobodan MILOSEVIC was
required to abide by the laws and customs governing the conduct of armed conflicts,
including the Geneva Conventions of 1949 and the Additional Protocols thereto.

51. All conduct charged as Crimes against Humanity was part of a widespread
or systematic attack directed against the Bosnian Muslim, Bosnian Croat and
other non-Serb civilian populations within large areas of Bosnia and Herzegovina.

ADDITIONAL FACTS

52. In November 1990, multi-party elections were held in Bosnia and Herzegovina.
At the Republic level, the SDA ("Stranka Demokratske Akcije - Party
of Democratic Action) the party of the Bosnian Muslims won 86 seats; the SDS,
the party of the Bosnian Serbs, won 72 seats and the HDZ (Hrvatska demokratska
zajednica - Croatian Democratic Community) won 44 seats in the Assembly.

53. The central idea within the SDS political platform, as articulated by its
leaders, including Radovan KARADZIC, Momcilo KRAJISNIK and Biljana PLAVSIC,
was the unification of all Serbs within one state. The SDS regarded the separation
of Bosnia and Herzegovina from the SFRY as a threat to the interests of the
Serbs.

54. On 5 February 1991 the Assembly of the Republic of Serbia passed a "Law
on Ministries" submitted by Slobodan MILOSEVIC. This law established
twenty "Ministries" of the Serbian government, including the Ministry
for Links with Serbs outside Serbia. This Ministry assisted the SDS to establish
the Serb Republic of Bosnia and Herzegovina.

55. The results of the November 1990 elections meant that, as time went on,
the SDS would be unable through peaceful means to keep the Republic of Bosnia
and Herzegovina in what was becoming a Serb-dominated Yugoslavia. As a result,
Serb people within certain areas of Bosnia and Herzegovina, with Serb majorities,
began to organise themselves into formal regional structures that they referred
to as "Associations of Municipalities." In April 1991 the Association
of Municipalities of Bosnian Krajina, centred in Banja Luka, was formed.

56. In March 1991, the collective Presidency of the SFRY reached a deadlock
on several issues including the issue of instituting a state of emergency in
Yugoslavia. The representatives on the Presidency from the Republic of Serbia,
the Republic of Montenegro, the Autonomous Province of Vojvodina, and the Autonomous
Province of Kosovo and Metohija all resigned from their posts. In a televised
address on 16 March 1991, Slobodan MILOSEVIC, in his capacity as President
of the Republic of Serbia, declared that Yugoslavia was finished and that Serbia
would no longer be bound by decisions of the Federal Presidency.

57. On 25 March 1991, Slobodan MILOSEVIC and Franjo TUDMAN met in Karadjordjevo
and discussed the partition of Bosnia and Herzegovina between Serbia and Croatia.

58. On 25 June 1991, Slovenia and Croatia declared their independence. On
26 June, the JNA intervened in Slovenia. In the summer of 1991, fighting broke
out in Croatia.

59. In August 1991 Radovan KARADZIC instituted a system of secret communication
between the local boards of the SDS and the Main Staff and with the Republic
of Serbia. This secret communication protocol was declared mandatory for the
transmission of reports and orders.

60. From autumn 1991, the JNA began to withdraw its forces out of Croatia.
Forces under the control of the JNA began to re-deploy in Bosnia and Herzegovina.
Many of these troops were deployed to areas in which there was no garrison or
other JNA facility.

61. As the war continued in Croatia it appeared increasingly likely that Bosnia
and Herzegovina would also declare its independence from the SFRY. The SDS,
realising it could not prevent the secession of Bosnia and Herzegovina from
the SFRY, began the creation of a separate Serbian entity within Bosnia and
Herzegovina. During the period from September to November 1991, several Serbian
Autonomous Regions (SAO) were formed, some of them on the basis of the Associations
of Municipalities referred to above.

62. On 12 September 1991, the Serbian Autonomous Region of Herzegovina was
proclaimed. On 16 September 1991, the Autonomous Region of Krajina was proclaimed
by the Assembly of the Association of Municipalities of Bosnian Krajina. By
21 November 1991, the Serbian Autonomous Regions and Autonomous Regions consisted
of the Autonomous Region of Krajina, the SAO Herzegovina, the SAO Romanija-Birac,
the SAO Semberija, and SAO Northern Bosnia.

63. On 3 October 1991, the four members of the SFRY Presidency from Serbia
and Montenegro (Borisav JOVIC, Jugoslav KOSTIC, Sejdo BAJRAMOVIC and Branko
KOSTIC) assumed the function of the SFRY Presidency, circumventing the roles
and responsibilities of the Presidency members from Slovenia, Croatia, Bosnia
and Herzegovina and Macedonia.

64. On 15 October 1991, at the meeting of the SDS Party Council the decision
was reached to form a separate assembly, entitled the "Assembly of the
Serbian People of Bosnia and Herzegovina" to secure Serb interests.

65. On or around 22 October 1991, Slobodan MILOSEVIC, together with
other members of the joint criminal enterprise, continued to advocate for a
unitary Serb state governed from Belgrade, Serbia. On the same date the "Rump
Presidency" called for the mobilisation of reservists in Serbia and "other
regions that want to stay in Yugoslavia."

66. On or about 26 October 1991, Radovan KARADZIC declared a full mobilisation
of the TO and the formation of field units in the Serb Republic of Bosnia and
Herzegovina.

67. On 24 October 1991, the Assembly of the Serbian People in Bosnia and Herzegovina,
dominated by the SDS, decided to conduct a "Plebiscite of the Serbian People
in Bosnia and Herzegovina" in order to decide whether to stay in the common
state of Yugoslavia with Serbia, Montenegro, the Serbian Autonomous Region of
Krajina, SAO Western Slavonia and SAO Eastern Slavonia, Baranja and Western
Srem.

68. On 9 and 10 November 1991, the Bosnian Serbs held the plebiscite on the
issue of whether Bosnia and Herzegovina should stay in Yugoslavia or become
an independent state. The results overwhelmingly showed that the Bosnian Serbs
wanted to stay in Yugoslavia.

69. On 21 November 1991, the Assembly of the Serbian People of Bosnia and
Herzegovina, proclaimed as part of the territory of the federal Yugoslav state
all those municipalities, local communities and populated places, in which over
50% of the people of Serbian nationality had voted, during the plebiscite, to
remain in that state as well as those places where citizens of other nationalities
had expressed themselves in favour of remaining in Yugoslavia.

70. On 11 December 1991, the Assembly of the Serbian People delivered a detailed
request to the JNA to protect with all available means as "integral parts
of the State of Yugoslavia" the territories of Bosnia and Herzegovina in
which the plebiscite of the Serbian people and other citizens on remaining in
a joint Yugoslav state had been conducted.

71. On 19 December 1991, the SDS issued instructions for the "Organisation
and Activity of the Organs of the Serbian People in Bosnia and Herzegovina in
Extraordinary Circumstances" which provided a plan for the SDS take-over
of municipalities in Bosnia and Herzegovina.

72. On 9 January 1992, the Assembly of the Serbian People of Bosnia and Herzegovina
adopted a declaration on the Proclamation of the Serbian Republic of Bosnia
and Herzegovina. The territory of that republic was declared to include "the
territories of the Serbian Autonomous Regions and Districts and of other Serbian
ethnic entities in Bosnia and Herzegovina, including the regions in which the
Serbian people remained in the minority due to the genocide conducted against
it in World War Two", and it was declared to be a part of the federal Yugoslav
state. On 12 August 1992, the name of the Bosnian Serb Republic was changed
to Republika Srpska.

73. From 29 February to 2 March 1992, Bosnia and Herzegovina held a referendum
on independence. At the urging of the SDS, the majority of Bosnian Serbs boycotted
the vote. The referendum resulted in a pro-independence majority.

74. On 18 March 1992, during the 11th session of the Assembly of
the Serbian People, a conclusion was reached to "prepare for the next session
proposals for the take-over of power in the Republic of Serbian People of Bosnia
and Herzegovina."

75. From March 1992 onwards, Serb regular and irregular forces seized control
of territories within Bosnia and Herzegovina, including those specified in this
indictment.

76. On 6 April 1992, the United States and the European Community formally
recognized the independence of Bosnia and Herzegovina.

77. On 27 April 1992, Serbia and Montenegro proclaimed a new Federal Republic
of Yugoslavia and declared it the successor state of the Socialist Federal Republic
of Yugoslavia.

78. On 12 May 1992, at the 16th Assembly of the Serbian People in Bosnia and
Herzegovina, Radovan KARADZIC announced the six strategic objectives of the
Serbian People in Bosnia and Herzegovina. These objectives included the eradication
of the Drina River as a border between the Serbian states. During the same session,
General Ratko MLADIC told the Assembly that it would not be possible to separate
Serbs from non-Serbs and have the non-Serbs simply leave the territory. He warned
that attempting this process would amount to genocide.

79. On 15 May 1992, the United Nations Security Council in its resolution
number 752 demanded that all interference from outside Bosnia and Herzegovina
by units of the JNA cease immediately and that those units either be withdrawn,
be subjected to the authority of the Government of the Republic, or be disbanded
and disarmed.

____________________________
Carla Del Ponte
Prosecutor

Dated this 22nd day of November 2001
At The Hague
The Netherlands

Schedule AKillings not Associated with Detention Facilities

No

Municipality

Victims (Killed)

Date

1

Banja Luka

In Culum-Kostic, 5 non-Serbs were killed.

15-Aug-92

2

Bihac

In Orasce and Duljci, approximately 18 non-Serbs were killed.

20-22 Sep 92

3

Bijeljina

In Bijeljina, at least 48 Bosnian Muslim and/or Bosnian Croat men, women
and children were killed.

1-2 Apr 92

4

Bosanska Gradiska

Killing of at least 4 Bosnian Muslim civilians near the market place
in Bosanska Gradiska.

15-Aug-92

5

Bosanski Novi

In Blagaj Japra, 7 Bosnian Muslim men were killed during the expulsion
of Bosnian Muslims.

09-Jun-92

In Alici, 27 Bosnian Muslim men were killed.

23-Jun-92

6

Bosanski Petrovac

Killing of at least 2 Bosnian Muslims near Hujici.

20-Sept-92

7

Bratunac

In Glogova, approximately 65 Bosnian Muslim and Bosnian Croat civilians
killed by members of the JNA, acting together with Serb paramilitary forces.

09-May-92

8

Brcko

In Brcko, approximately 12 Bosnian Muslim males and other non-Serbs were
killed at the Hotel Posavina.

04-May-92

9

Celinac

Rifet MUJKANOVIc, shot to death by Serb soldier.

31-July-92,

Killing of 2 non-Serb civilians by Serb soldiers.

2-Aug-92,

10

Doboj

In Gornja Grapska, approximately 34 Bosnian Muslim civilians were killed
during shelling of village.

10-May-92

11

Foca

In DDjidjevo, at least 11 Bosnian Muslim men were executed by Serb soldiers.

20-Apr-92

In Filipovici, at least 5 Bosnian Muslims were killed by Serb soldiers
in a military warehouse.

26-Apr-92

In Jelec, 18 Bosnian Muslims, including elderly people and 8 members
of one family, were executed by JNA soldiers.

4-10-May-92

In Brod, 14 Bosnian Muslim men from Trnovaca were executed by Serb soldiers.

22-Jun-92

12

Gacko

At least 5 non-Serbs killed in the village of Meduljici

17-June-92

2 Muslim males killed by Serbs in a field near Mount Zelengora

18-June92

At least 8 Muslims killed by Serb soldiers near Mount Zelengora

18-23-June-92

13

Kljuc

In Pudin Han, 11 Bosnian non-Serb civilians were killed during the Serb
attack on the village.

27-May-92

In Prhovo, 38 Bosnian Muslim villagers, including women and children,
were killed by shooting and grenades.

01-Jun-92

Near Peci, 9 Bosnian Muslim men were killed by Serb soldiers.

01-Jun-92

In Velagici, approximately 100 Bosnian Muslim men were killed.

01-Jun-92

14

Kotor Varos

In Kotor Varos town, approximately 13 non-Serbs were killed in and around
the Medical Centre.

25-Jun-92

In a barn in Dabovci, at least 15 Bosnian Muslim men were killed.

Aug-92

In Vrbanjci 7 Bosnian Muslim men were killed in and around the Alagic
café.

25-Jun-92

In Grabovice, a large number of Bosnian Muslim and Bosnian Croat detainees
were held in the Grabovice School, beaten and never seen again.

Nov-92

15

Nevesinje

At or near Lipovaca and Dubrovaci, at least 34 Bosnian Muslim men, women
and children were killed.

Jun-Jul-92

Near Kiser, approximately 17 Bosnian Muslim civilians were killed by
Serb soldiers.

mid July-92

16

Prijedor

In the Brdo region numerous non-Serbs were killed.

Jul-92

In Hambarine and Behlici, at least 3 Bosnian Muslims were killed.

11-Jun-1-Jul-92

In Kamicani, approximately 8 non-Serbs were killed in Mehmed Sahoric's
house.

At Geroís slaughter-house, approximately 190 non-Serb detainees were
killed.

07-Jun-92

20

Novi Grad

(Sarajevo)

Near Srednje, 47 Bosnian Muslim men from Rajlovac camp were killed.

14-Jun-92

Schedule CDetention Facilities

No

Municipality

Detention Camp

Dates

1

Banja Luka

Former JNA Barracks Mali Logor (Military Remand Prison)

Aug-Sep-92

Viz Tunjice Penitentiary

Jun-Nov 92

Manjaca Camp

Jun-Dec-92

2

Bihac

Traktorski Servis, Ripac (garages and houses)

Jul-Oct-92

3

Bijeljina

Batkovici Detention Centre

Jul-92-Jun-95

New Slaughterhouse (Nova Klaonica)

From Mar 92

4

Bileca

SUP Detention facility.

10 June- 19 Dec 1992

Student Hostel (Dacki Dom).

25 June - 5 Oct 1992

5

Bosanska Dubica

SUP Building

Jun-Sep 92

6

Bosanska Krupa

Petar Kocic Elementary School

Apr-Sep-92

Jesenica Primary School

Apr-Sep-92

7

Bosanski Samac

Crkvina Camp

May - Oct 92

8

Bosanski Novi

Bosanska Kostajnica Police Station

May-Jul-92

Mlakve Football Stadium

Jun-Jul-92

Bosanski Novi Fire Station

Jul-Aug 92

9

Bosanski Petrovac

Kozila Camp

May-Aug 92

10

Brcko

JNA Barracks Brcko

Apr-Jul 92

Luka Detention Centre

04-May-13-Jul-92

11

Bratunac

Vuk Karadzic School

Jul-92

12

Cajnice

Mostina Hunting Lodge

April, May 1992

Cajnice SUP building.

June-July 1993

13

Celinac

Municipal building in Celinac

1-Aug-92

14

Doboj

Spreca Prison

Apr 92-Feb 93

Percinís Disco (restaurant Kod Perco)

May - Aug-92

Ammunition Warehouse, Bare

May-92

SUP Station

May-Aug 92

JNA Hangars near Bosanska Plantation (Bosanka Camp)

May-92- Jun-93

Seslija Camp

Mar-Oct-93

15

Donji Vakuf

Vrbas Promet camp.

11-June-92

"The House," a house across the street from the MUP building

07-June-92

SUP building

16-June-92

TO warehouse.

16-June-92

16

Foca

Foca High School (Sredsnjoskola Centar)

Jun-92

Partisan Sports Hall

Jul-92

Livade Camp

Apr-92

KP Dom Prison

Apr-92 - Oct-94

17

Gacko

Dom Kulture Avtovac.

01-June-92

SUP building

08-June 92 - 05-July-92

Hotel connected to power plant

01-May-92

Hotel "Metohija"

01-May-92

18

Kalinovik

Kalinovik School (primary/elementary).

Jul 92- Sept 92

Gunpowder warehouse between Jelasica and JazIcI.

5 July-5-Aug-92

19

Kljuc

Nikola Mackic Elementary School

May-92

20

Kotor Varos

Kotor Varos Prison

Jun - Nov-92

Kotor Varos Sawmill

Jun-92

Kotor Varos Police Station

May-Sep 92

Kotor Varos Elementary School

Aug-Sep 92

21

Nevesinje

Central Heating Factory (Kilavci)

Jun-Jul 92

22

Prijedor

Omarska Camp

May - Aug-92

Keraterm Camp

May-Aug-92

Miska Glava

Jul-92

Prijedor Barracks

May-Jun 92

Trnopolje Camp

May-Dec-92

23

Prnjavor

Stari Mlin

Oct-92 - Mar-94

Sloga Shoe Factory

May-Dec 92

Ribnjak

Nov-92-Jan- 93

24

Rogatica

Veljko Vlahovic School

May-92 - Early-93

Rasadnik

Jun-92 - Jun-93

25

Rudo

Basement of the cultural centre.

June-93 - Feb -94

26

Sanski Most

Krings Factory

May-Aug-92

Hasan Kikic School

May - Jun-92

Betonirka Cement Factory

May -Jul-92

Boiler Room of Old Hotel.

21-Sep-95 to 25-Sep-95

27

Sokolac

KTK Leather Factory.

July- Dece 92

"Slavisa Vajner Cica Elementary School.

Planja's house.

Cavarine.

28

Teslic

Pribinic (old post office)

Jun-Oct 92

TO Building

Jun-92

SUP Building

Jun-92

29

Visegrad

Detention centre in tourist hotel in Vilina Vlas.

01-Ma-92

Uzamnica, a former military warehouse and barracks.

Aug-92 - Oct-94

30

Vlasenica

Susica Territorial Defence Installation

Jun-92

31

Zvornik

Celopek Dom Kulture

May-Jul 92

Karakaj Technical School

May-Jul 92

Novi Izvor Building, Zvornik town

Apr-Sep-92

Ekonomija Farm, Karakaj

Jun-Aug 92

Schedule DForcible Transfers

No

Municipality

Non-Serb Displaced Persons and Refugees

Deportations

TOTAL NUMBER EXPELLED - 268,050

1

Banja Luka

19359

Hungary

2

Bileca

993

Montenegro

3

Bihac

2588

4

Bijeljina

13159

5

Bosanska Krupa:

- Bosanska Krupa

1439

- Buzim

389

- Krupa na Uni

1

6

Bosanska Dubica

3310

7

Bosanska Gradiska

7516

8

Bosanski Novi

6288

9

Bosanski Petrovac:

- Bosanski Petrovac

778

- Petrovac

unknown

10

Bosanski Samac:

Croatia

- Samac

1563

- Domaljevac-Samac

217

11

Bratunac

8048

12

Brcko:

- Brcko

14607

- Ravne / Rahic

1532

13

Cajnice

2214

14

Celinac

608

15

Doboj:

- Doboj

18569

- Doboj Istok

405

- Doboj Jug

310

16

Donji Vakuf

1729

17

Foca:

- Foca / Srbinje

8258

- Foca FBiH

1039

18

Gacko

1899

Macedonia

19

Gorazde:

- Gorazde FBiH

2563

- Srpsko Gorazde

1834

20

Kalinovik

612

21

Kljuc:

- Kljuc

3852

- Kljuc / Ribnik

26

22

Kotor Varos

6870

23

Nevesinje

1483

24

Prijedor

20256

25

Prnjavor

3490

26

Rogatica

6650

27

Rudo

1614

Macedonia

28

Sanski Most:

- Sanski Most

6257

- Srpski Sanski Most

221

29

Srebrenica

25,000

30

Sekovici

162

31

Sipovo

1427

32

Sokolac

2670

33

Teslic

7789

34

Trebinje:

- Trebinje

3116

- Ravno

201

35

Visegrad

6690

36

Vlasenica

6942

37

Zvornik:

Hungary;Austria

- Zvornik

15436

- Sapna

1335

CITY OF SARAJEVO

38

Ilidza:

- Ilidza

218

- Srpska Ilidza

60

39

Novi Grad Sarajevo

9008

40

Novo Sarajevo:

- Novo Sarajevo

7097

- Srpsko Novo Sarajevo

4

41

Vogosca

2099

GREATER SARAJEVO

42

Hadzici

1390

43

Ilijas

1889

44

Pale:

- Pale

1697

- Pale FBiH

115

45

Trnovo:

- Trnovo RS

744

- Trnovo FBiH

415

Schedule ESarajevo Sniping Incidents

No

Incident

Date

1

Fadila ZGODIC, a woman aged 52 years, was shot and wounded in the hip
while carrying bread near Darovalaca Krvi Street, presently Kolodvorska
Street, in the area of Novo Sarajevo.

07-Nov-92

2

Anisa PITA, a girl aged 3 years, was shot and wounded in the right leg
as she was taking off her shoes while on the porch of her residence on
Zagrici Street in the Sirokaca area of Sarajevo.

13-Dec-92

3

The victim, a girl aged 9 years, was shot and wounded in the back as
she played in the front garden of her house in the Sedrenik area of Sarajevo.

17-Apr-93

4

Muhamed HAZNADAREVIC, a man aged 52 years, was shot and wounded in the
back and chest while trying to tend a vegetable plot in Slatinski Put
5, presently Slatinski Put 13, Kobilja Glava, north of Sarajevo.

25-Jun-93

5

Almasa KONJHODZIC, a woman aged 56 years, was shot dead near the junction
of Dure Dakovica and Kranjcevica Street, presently Alipasina and Kranjcevica,
while walking with her family.

27-Jun-93

6

Munira ZAMETICA, a woman aged 48 years, was shot dead while collecting
water from the Dobrinja River in area of Dobrinja II and III.

11-Jul-93

7

Hajrija DIZDAREVIC, a woman aged 66 years, was shot dead in her apartment
at Kranjcevica 11/5, presently Dzamijska Street, during her prayers.

On or about 17-07-1993

8

Mejra JUSOVIC, a woman aged 45 years, was shot and wounded while pulling
a load of wood towards her home near Rasadnjak, Sedrenik area, Sarajevo.

24-Jul-93

9

Vildana KAPUR, a woman aged 21 years, was shot and wounded in the leg
while transporting water home along Stara cesta, Hotonj area.

05-Aug-93

10

Nafa TARIC, a woman aged 35 years, and her daughter Elma TARIC, aged
8 years, were shot by a single bullet while walking together in Ivana
Krndelja Street, in the centre of Sarajevo. The bullet wounded the mother
in the left thigh and wounded the daughter on the hand and in the abdomen.

03-Sep-93

11

Sacir BOSNIC, a man aged 56 years, was shot dead while gathering wood
across the road from the Hambina Carina Reservoir and adjacent to Zelengorska
Street, presently Hambina Carina Street, at Sirokaca, Skenderija.

Faruk KADRIC, a boy aged 16 years, was shot and wounded in the neck while
riding as a passenger in his fatherís truck along Ante Babica Street,
in the west end of Sarajevo.

04-Oct-93

14

Edin RAMOVIC, a man aged 29 years, was shot and wounded in the left upper
arm while walking in Stara cesta Road, in the Bare area of Sarajevo.

07-Oct-93

15

Ramiz VELIC and Milan RISTIC, aged 50 and 56 years respectively, were
wounded by a burst of gunfire while they were working clearing rubbish
along Brace Ribara Street, presently Porodice Ribar Street, in the Hrasno
area of Sarajevo.

02-Nov-93

16

Ramiza KUNDO, a woman aged 38 years, was shot and wounded in the left
leg while she and another woman were returning from a water well carrying
buckets of water near Brijesko Brdo Street, presently Bulbulistan Street,
in the west end of Sarajevo.

02-Nov-93

17

Fatima OSMANOVIC, a woman aged 44 years, was shot and wounded in the
right side of her face while she was carrying water in Brijesko brdo Street,
presently Bulbulistan Street, in the west end of Sarajevo.

13-Nov-93

18

Sanija DZEVLAN, a woman aged 32 years, was shot and wounded while riding
a bicycle across a bridge in Nikola Demonja Street, Dobrinja.

Hetema MUKANOVIC, a woman aged 38 years, was shot and killed in her apartment
on the first floor of Obala 27. Jula 89/I, presently Aleja Lipa 64, in
the Hrasno area of Sarajevo. At the time she was sitting with her husband
and neighbours, drinking coffee by candlelight.

11-Jan-94

21

Ivan FRANJIC, a man aged 63 years, was walking with two others on Ante
Babica Street in Vojnicko Polje, in the west end of Sarajevo. He was shot
and wounded in the stomach while one of his companions Augustin VUCIC
was shot and later died from his injuries.

13-Mar-94

22

Sadeta PLIVAC, a woman aged 53 years and Hajra HAFIZOVIC a woman aged
62 years, were both shot and wounded in their legs while passengers in
a crowded bus near the junction of Nikolje Demonje and Bulevar AVNOJ,
presently Nikolje Demonje and Bulevar Branioca Dobrinja, in Dobrinja.

25-May-94

23

Fatima SALCIN, a woman aged 44 years, was shot and wounded in the hand
when walking with her father-in-law in Ive Andrica Street, in the Mojmilo
area of Sarajevo.

13-Jun-94

24

Sanela MURATOVIC, a girl aged 16 years, was shot and wounded in the right
shoulder while walking with a girlfriend in Dure Jaksica Street, presently
Adija Mulabegovica, in the west end of Sarajevo.

26-Jun-94

25

Jasmina KUCINAR, a pregnant woman aged 31 years, and her son Damir KUCINAR,
aged 4 years, were lightly wounded in the legs by a shot penetrating a
crowded tram in which they were travelling. The tram was travelling west
on Zmaja od Bosne Street towards Alipasino Polje. Mensur JUSIC, a man
aged 36 years, sustained a slight leg wound and Belma SUKIC nee LIKIC,
a woman aged 23 years, was wounded in the left armpit in the same attack.
The tram was near the Holiday Inn hotel at the time of the incident.

6-10-Jul-94

26

Rasid DZONKO, a man aged 67 years, was shot and wounded in the back whilst
sitting watching television in his apartment situated at Milanka Vitomira
Street, presently Senada Mandica Dende Street 5 in Vojnicko Polje, in
the west end of Sarajevo.

17-Jul-94

27

Seid SOLAK, a boy aged 13 years, shot and wounded in the abdomen whilst
window shopping with his mother and sister in Miljenka Cvitkovica Street,
presently Ferde Hauptmana, in the Cengic Vila area of Sarajevo.

22-Jul-94

28

Alma CUTUNA, a woman aged 43 years, was wounded in the right upper leg
while travelling on a tram on Zmaj od Bosne Street in Sarajevo.

08-Oct-94

29

Adnan KASAPOVIC, a boy aged 16 years, was shot in the chest and killed
while walking in an alley adjoining Dordje Andrijevica Kuna Street.

24-Oct-94

30

Fata GUTA, a woman aged 59 years, was shot and wounded in the hand while
she was going with jerri-cans to collect water from the Moscanica spring
in Gazin Han, to the east of Sarajevo.

08-Nov-94

31

Sanja SMJECANIN, a pregnant woman aged 28 years, was shot and wounded
while travelling with her husband and sister-in-law in a car on Zmaj od
Bosne Street.

09-Nov-94

32

Dzenana SOKOLOVIC, a woman aged 31 years, and her son Nermin DIVOVIC,
a boy aged 7 years, were fired on while walking in Zmaj od Bosne Street.
Ms. SOKOLOVIC was wounded with a bullet in the abdomen. The bullet passed
through her and hit her son in the head, killing him. They had been walking
home from Hrasno, where they had gone to collect firewood the previous
day.

18-Nov-94

33

Hajrudin HAMIDIC, a man aged 52 years, was wounded in the arm and face
when the tram he was driving westbound on Zmaj od Bosne was fired on.

21-Nov-94

34

Sanela DEDOVIC, a girl aged 12 years, was wounded in the left ankle while
she was walking to school. The incident occurred at the junction of Sedrenik
Street and RedĎepa Gorusanovica Street, in the north east corner of Sarajevo.

22-Nov-94

35

Hafiza KARACIC, a woman aged 31 years and Sabina SABANIC, a woman aged
26 years, were both wounded in the right shoulder when the tram they were
travelling on came under fire on Zmaj od Bosne, between the Technical
School and Marshal Tito Barracks.

23-Nov-94

36

Lejla BAJRAMOVIC, a woman aged 24 years, was sitting in a friendís apartment
in Franca Lehara Street, near the centre of Sarajevo, when she was shot
in the head and killed. The shot came through the apartment window.

08-Dec-94

37

Dervisa SELMANOVIC, a woman aged 49 years, was shot and wounded in the
right knee while she was gathering firewood in the backyard of a house
in Sedrenik Street, in the north east end of Sarajevo.

10-Dec-94

38

Malkan PLEHO, a man aged 62 years, was shot and wounded in the right
lower leg while climbing the front steps to his house in Sedrenik, in
the north east end of Sarajevo.

11-Dec-94

39

Halid DEMIROVIC, a man aged 62 years, was shot and wounded in the right
heel while he was gathering firewood on Pasino Brdo, in the north east
corner of Sarajevo.

13-Dec-94

40

Senad KESMER, a man aged 31 years, Alma CEHAGIC, a woman aged 19 years,
Alija HOLJAN, a man aged 55 years, and others, were shot and wounded while
travelling in a westbound tram on Zmaj od Bosne Street. The tram was near
the Tito Barracks at the time.

27-Feb-95

41

Azem AGOVIC, a man aged 46 years and Alen GICEVIC, a man aged 33 years,
were shot and wounded while travelling in an eastbound tram on Zmaj od
Bosne Street. The tram was near the Holiday Inn at the time.

03-Mar-95

42

Tarik ZUNIC, a boy aged 14 years, wounded in the hand while he was walking
home from school at Sedrenik Street, in the north east of Sarajevo. He
emerged from behind a protective screen, about 100 metres from home, when
he was hit.

06-Mar-95

43

Vahid BALTA, a man aged 52 years, was walking with his wife in Sedrenik
Street, in the north east of Sarajevo, when he was shot in the ankle.

06-Mar-95

44

A young man was crossing the junction of Nikole Demonje and Bulevar Avnoj
Streets in the Dobrinja area, when he was shot in the left side and killed.

18-Mar-95

45

Semsa COVRK, a woman aged 27 years, was shot and wounded in the abdomen
while walking in Josipa Krasa Street, Novi Grad, holding her young sonís
hand at the time.

03-May-95

46

A man was shot and killed in Dinarska Street, Hrasno Brdo.

13-May-95

47

Durgut COBIC, a man aged 80 years, was shot and wounded in the shoulder
when he opened the balcony of his apartment door Kunovska Street 4/I,
Dobrinja.

25-May-95

Schedule FSarajevo: Shelling Incidents

No

Incident

Date

1

Two shells were fired upon a crowd of approximately 200 persons who were
watching and participating in a football game in a parking lot bordered
on three sides by residential apartment blocks and on the fourth side
by the Lukavica Road in Dobrinja 3B, a residential settlement. At least
twelve people, including 3 children under the age of 15 years, were killed
and at least 70 people, including 10 children, were wounded. The origin
of fire was VRS-held territory approximately to the east-south-east.

01-Jun-93

2

An 82 mm mortar shell was fired upon about 100 civilians who were waiting
to access a communal water pump in the front yard of a residence at 39
Hakije Turajlica (previously Aleja Branka Bulica then Spasenije Cane Babović)
in Dobrinja, a residential settlement. At least twelve people were killed
and fourteen people were wounded. The origin of fire was VRS-held territory
approximately to the west-north-west.

12-Jul-93

3

Three mortar shells landed in the area of Alipasino Polje, the first
in a park behind, and the second and third in front of residential apartment
buildings at 3 Geteova Street (previously Centinjska Street) and at 4
Bosanska Street (previously Klara Cetkin Street), where children were
playing. The second and third shells killed six children under the age
of 15 years and wounded one adult and four such children. The origin of
fire was from VRS-held territory approximately to the west.

22-Jan-94

4

A salvo of three 120 mm mortar shells hit civilians in the Dobrinja residential
area. The first landed to the front of a block of flats at Oslobodilaca
Sarajeva Street hitting persons who were distributing and receiving humanitarian
aid and children attending religious classes. The second and third landed
among persons trading at a market in an open area to the rear of the apartment
buildings at Mihajla Pupina Street and Oslobodilaca Sarajeva Street. Eight
people, including 1 child under the age of 15 years, were killed and at
least 18 people, including 2 children were wounded. The origin of fire
was from VRS-held territory, approximately to the east.

04-Feb-94

5

A 120 mm mortar shell hit a crowded open air market called "Markale,"
situated in a civilian area of Old Town Sarajevo, killing 66 people and
wounding over 140 people, including 3 children under the age of 15 years.
The origin of fire was VRS-held territory approximately to the North-North-East.

05-Feb-94

6

A 120 mm mortar shell impacted on the Igman Road amongst a group of civilians
at a bus stop. One person was killed and fifteen were injured. The origin
of fire was Vojkovici VRS territory.

30-Oct-94

7

Three mortar shells struck Livanjska Street, a street of civilian dwellings.
Two persons were killed and six were injured. The origin of fire was Poljine
direction VRS territory.

08-Nov-94

8

One 120 mm mortar shell hit Partizanska Street 18 in Hrasnica. Two children
aged eight years and two years were killed and three adults were injured.

17-Nov-94

9

An 82 mm mortar shell hit adjacent to a civilian dwelling killing an
elderly man and injuring his elderly wife. The origin of fire was VRS
territory.

12-Dec-94

10

Two 76 mm shells in quick succession hit a flea market in the old commercial
quarter of Bascarsija in Old Town. Two persons were killed and seven were
injured. The origin of fire was Trebevic, VRS positions.

22-Dec-94

11

A modified aircraft bomb hit a residential area in Hrasnica at the foot
of Mount Igman destroying one dwelling, severely damaging eleven other
dwellings. One person was killed and three injured. The origin of fire
was Ilidza, VRS territory.

07-Apr-95

12

A 60 mm mortar shell hit a concrete area near the Sarajevo railway station.
Seven people were injured. The origin of fire was Zlatiste, VRS territory.

12-Apr-95

13

A missile landed and exploded on the asphalt of Safeta Zajke street at
approximately 9.45, killing two and injuring five people. The missile
came from the southeast, direction of Lukavica.

24-May-95

14

A modified air-bomb landed at Majdanska Street bb. Two civilians were
killed and six were wounded. The origin of fire was from the southeast
VRS territory of Pavlovac.

24-May-95

15

A modified air-bomb struck a building near apartment blocks in Safeta
Hodzica Street, destroying the top three floors of an apartment building.
This explosion was followed by several artillery rounds landing in the
same area. Serious damage was caused to a number of buildings. Two people
were seriously injured and fifteen persons were slightly injured. The
fire was determined to have come from VRS territory to the West/ Southwest.

26-May-95

16

At about 10.00 hours, a modified aircraft bomb was fired from the North
West. The bomb landed and exploded on the building of the UMC and Oncology
Department at Dositejeva street 4-a. There was a lot of damage and three
persons were slightly injured.

16-Jun-95

17

At about 15.20 hours, a modified aircraft bomb, most probably fired from
Lukavica, exploded next to 10, Trg Medjunarodnog Prijateljstva, slightly
injuring seven people and causing considerable damage to neighboring buildings.

16-Jun-95

18

At 17.20 hours, a modified aircraft bomb was fired from the North West.
It exploded on the builder house at Cobanija Street 7. Two people were
wounded.

16-Jun-95

19

A 120 mm mortar shell struck a line of civilians, numbering approximately
50-70, waiting for water distribution in Marka Oreskovica Street, Dobrinja.
Seven people were killed and twelve injured. The origin of fire was Nedzarici,
VRS territory.

18-Jun-95

20

A projectile was fired into the street Bulevar Mese Selimovica, probably
from the direction of Rajlovac. There were no victims.

29-Jun-95

21

At about 13.30 hours, a high impact missile landed just outside the house
number 5 in Radenko Abazovica. It was fired from the Western part of the
city (Ilidza - Rajlovac). There were no victims.

01-Jul-95

22

At about 21.30 hours, a rocket projectile with a concussion warhead exploded
in Bunicki Potok street. Thirteen people were injured. The projectile
came from Ilidza.

01-Jul-95

23

A 120 mm mortar shell hit close to a dwelling at Vrbanjusa 95 (a residential
area). One boy was killed. The origin of fire was VRS territory in the
South.

19-Jul-95

24

A rocket missile with concussion warhead, coming from the direction of
Ilidza/ Blazuj, landed on the house Sokolovici, Bjelasnicka Street 54.
Two persons were killed and eleven were lightly wounded.

23-Jul-95

25

A modified explosive device exploded at the staircase between the 2nd
and the 3rd floor of the BITAS building in Zmaja od Bosne Street 64. One
person died, another received light injuries. The origin of fire was VRS
territory in the South West.

22-Aug-95

26

A 120 mm mortar shell landed in Mula-Mustafe Baseskije Street outside
the entrance to the City Market. 43 people were killed and 75 were injured.
The origin of fire was Trebevic, VRS territory.